Trading in the Securities of Albemarle or our Business Partners

CODE PRINCIPLES

Employees may be entrusted with material non-public information relating to Albemarle or its business partners in the performance of their jobs. This trust must never be violated by using the information for financial or personal benefit.

Our Code Principles in Action

DEFINED TERMS

Business Information

May include marketing plans; proprietary perspectives on the market; cost data; details of negotiations with individual customers or suppliers; current or recent terms of sale or purchase; strategic information relating to asset expansion, joint venture or M&A activity; salaries and other terms of employee remuneration; innovation plans and intellectual property; production, export, sales and purchase data and any other financial data or forecasts.

Material Non - Public Information

“Non-public” information is any confidential information concerning Albemarle or its affairs (extending to customers, suppliers and business transactions). Information is considered to be “material” if a reasonable investor would be likely to take the information into account when deciding whether to buy, sell or hold Albemarle securities. Any information that could be expected to affect the price of Albemarle securities, whether it is positive or negative, should be considered material. There is no bright-line standard for assessing materiality; rather, materiality is based on an assessment of all of the facts and circumstances, and is often evaluated by enforcement authorities with the benefit of hindsight.

By way of example, material non-public information can include information about topics such as sales, earnings, projections, corporate developments, new products, research projects, impairments, layoffs, acquisitions, divestitures, financings, joint ventures, threatened or actual litigation, and other business matters concerning customers, suppliers or other companies with whom the Company does business or has relationships.

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